IOM FSA publishes findings of Moneylenders thematic review
26/08/2025
The Isle of Man Financial Services Authority has published the findings from Phase 2 of a thematic review relating to the Island’s Moneylenders and due diligence.
A total of 20 Moneylenders were selected to take part in on-site inspections to build on the data gathered via responses to a questionnaire issued during the initial phase of the project.
The thematic inspections assessed how Moneylenders are meeting their obligations in respect of the AML/CFT Code 2019, specifically in relation to
- customer due diligence (“CDD”) and
- enhanced customer due diligence (“ECDD”),
- source of funds (“SOF”) and
- source of wealth (“SOW”)
There were three main objectives of the Phase 2 inspections: Procedures and Controls, New Business Relationships and Enhanced Customer Due Diligence.
The thematic project aimed to assess firms’ controls against money laundering, terrorist financing, and proliferation financing (“ML/TF/PF”) risks posed to the designated business sector.
The Moneylenders Phase 2 Report, which can be accessed on the Publications section of the Authority’s website, sets out the key takeaways, examples of good practice and areas for improvement, together with the Authority’s observations on the findings.
Firms from all licensed and registered sectors are encouraged to read the Phase 2 report and consider any action necessary to ensure their own CDD and ECDD (including SOF and SOW) procedures and controls are practical, up-to-date and adequately documented.
SOURCE
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As well as owning and publishing Comsure's copyrighted works, Comsure wishes to use the copyright-protected works of others. To do so, Comsure is applying for exemptions in the UK copyright law. There are certain very specific situations where Comsure is permitted to do so without seeking permission from the owner. These exemptions are in the copyright sections of the Copyright, Designs and Patents Act 1988 (as amended)[www.gov.UK/government/publications/copyright-acts-and-related-laws]. Many situations allow for Comsure to apply for exemptions. These include 1] Non-commercial research and private study, 2] Criticism, review and reporting of current events, 3] the copying of works in any medium as long as the use is to illustrate a point. 4] no posting is for commercial purposes [payment]. (for a full list of exemptions, please read here www.gov.uk/guidance/exceptions-to-copyright]. Concerning the exceptions, Comsure will acknowledge the work of the source author by providing a link to the source material. Comsure claims no ownership of non-Comsure content. The non-Comsure articles posted on the Comsure website are deemed important, relevant, and newsworthy to a Comsure audience (e.g. regulated financial services and professional firms [DNFSBs]). Comsure does not wish to take any credit for the publication, and the publication can be read in full in its original form if you click the articles link that always accompanies the news item. Also, Comsure does not seek any payment for highlighting these important articles. If you want any article removed, Comsure will automatically do so on a reasonable request if you email info@comsuregroup.com.